Safe Water Quest: Tackling Lead Exposure With Service Line Inventories (Updated October 2024)
The US Environmental Protection Agency (US EPA) mandated that all public water systems develop an inventory of their service lines and prepare a lead service line replacement plan by October 2024. Communities have acted swiftly to meet this rule, published as the Lead and Copper Rule Revisions (40 CFR Part 141, 40 CFR Part 142). Here we break down the regulations, who is responsible, how to comply, transparency, and finally, funding.
Lead in Drinking Water
Water service lines supply drinking water from the water main to the home. When service lines made of lead (lead service lines) corrode, lead can enter the water and contribute to lead exposure in drinking water. Lead presents serious health concerns, particularly for infants and young children, that have earned the US EPA’s attention since 1991 when the first Lead and Copper Rule (LCR) was published. In 2021, the US EPA released the Lead and Copper Rule Revisions (LCRR), which drove today’s compliance requirement for lead service line inventory and replacement plans. On October 8, 2024, the US EPA issued a final rule requiring the replacement of lead pipes within 10 years under the National Primary Drinking Water Regulations for Lead and Copper Rule Improvements (LCRI).
The US EPA published the “Rule Comparison Guide for Public Water Systems and Primary Agencies” to assist in understanding the proposed LCRI.
Key components of the final LCRI include:
- Achieving 100% lead pipe replacement within 10 years
- Locating legacy lead pipes
- Improving tap sampling
- Lowering the lead action level
- Strengthening protections to reduce exposure
Today’s Regulations
To comply with the LCRI, water systems are required to annually update their lead service line inventory and complete a baseline inventory to include additional information about connector materials and locations within 3 years of the LCRI’s publication. This catalog of service lines becomes a living dataset and the foundation for a comprehensive approach to identifying and replacing lead service lines, educating the community, and tackling lead exposure in drinking water.
Responsible Entities
Those subject to the LCRI include:
- Community Water Systems: Public water systems that serve at least 15 service connections used by year-round residents or regularly serve at least 25 year-round residents (40 CFR §141.2)
- Non-transient, Non-community Water Systems: Public water systems that are not community water systems and regularly serve at least 25 of the same persons over six months per year (40 CFR §141.2)
While there are a variety of ownership agreements for providing water service in the US, the rules require that both water system-owned and customer-owned portions of service lines are inventoried. Water system providers are responsible for the inventory of all users connected to their system, including out-of-district users. Responsibility can be complex though. For example, when a village water district provides water to a consecutive town system, such as a system with a master meter at the village limit, the village bills the town in bulk and the town bills the individual customers. In this arrangement, the consecutive system (the town) is responsible for the town inventory. However, in a customer-based intermunicipal arrangement where a village bills customers in both the village and the town, the village is responsible for the inventory of all customers served in both the village and in the town.
Inventory Components
Public water systems were required to prepare and maintain an inventory of service line materials or demonstrate the absence of lead service lines by October 16, 2024.
The lead service line inventory includes the following elements:
- Materials classification (lead, galvanized requiring replacement, non-lead, unknown) of water system-owned and customer-owned portions of each service line connected to the public water distribution system
- Location identifier for any lead or galvanized service line requiring replacement
- Inventory must be made publicly available
Additional elements are recommended to support asset management, document the existence of lead connections, and streamline future reporting. The US EPA’s Guidance for Developing and Maintaining a Service Line Inventory, Service Line Inventory Template, and Final LCRI Service Line Inventory and Replacement Requirements Fact Sheet outline these requirements and additional recommendations.
Replacement Plans
Additionally, water systems were required to submit a lead service line replacement plan by October 16, 2024, with lead service lines, galvanized service lines requiring replacement (galvanized lines that are or were downstream of a lead service line or cannot be verified otherwise), or lead status unknown service lines (material is unknown).
The lead service line replacement plan should include:
- Strategy for determining materials of lead status unknown service lines
- Procedure for conducting full lead service line replacement
- Strategy for informing customers before a replacement
- Procedures to flush lines
- Replacement prioritization strategy
- Funding strategy
Mandatory Service Line Replacement
Under the US EPA’s final rule, water systems must fully replace all lead and GRR service lines under their control within 10 years unless the state provides a shortened or deferred deadline.
- Replacing all lead and GRR service lines under water system control within 10 years
- Implementing 10% cumulative average annual replacement rate
- Obtaining property owner consent
- Offering full-service line replacement within 6-months of change of ownership of property
- Replacing lead connectors under water system control when encountered
For any service line replacement, notification and risk mitigation measures must occur before the affected line is returned to service. Additionally, the water system must offer to collect a follow-up tap sample between three to six months after the replacement to test for lead.
Public Transparency
Public health is at the center of the US EPA’s actions to protect individuals and lead service line inventories require public transparency. Community water systems and non-transient, non-community water systems must make a portion of their inventory publicly available. Where lead, galvanized requiring replacement, or lead status unknown lines are identified, water systems must notify the public or users of the involved building(s) through an annual notice to all existing and new customers served. If a water system serves more than 50,000 people, the inventory must be publicly available online.
Funding for Inventories and Replacements
State and federal funding is available to assist municipalities in completing lead service line inventories and replacements. Additional funding and other grant programs that support healthy, thriving communities may become available to reduce costs.
| AGENCY | PROGRAM TITLE | MAXIMUM GRANT | LOCAL MATCH |
| Bipartisan Infrastructure Law | BIL Lead Service Line | $15,000,000 over the next five years (FY 2022-2026) for identification and replacement | Defined by state, refer to Drinking Water State Revolving Fund (DWSRF) Priority Listing information |
| US Housing and Urban Development (HUD) Office of Community Renewal | Community Development Block Grant (CDBG) | Varies by state and community. NYS non-entitlement is $1,000,000 for CDBG Public Infrastructure | None Identified |
| US Environmental Protection Agency | Water Infrastructure Finance and Innovation Act | Long-term, low-cost supplemental loans. $20 million minimum project size for large communities. $5 million minimum project size for small communities. | |
| US Environmental Protection Agency | WIIN Reducing Lead in Drinking Water Grant in Disadvantaged Communities and Schools | $10,000,000 | 20% of total project |
| US Economic Development Administration | Public Works and Economic Development Program | $600,000 – $5,000,000 | 20% – 50% dependent on economic distress level |
| US Department of Agriculture Rural Development | Water & Waste Disposal Loan & Grant Program | Long-term loans with repayment over 40 years. Grants may be available. | |
| National Rural Water Association | Rural Water Loan Fund | Long-term loans up to $200,000 or 75% of project costs. Emergency loans are 90-day with no interest. Immediate turnaround on applications. | |
| State Agencies | Drinking Water State Revolving Fund (DWSRF) – distribution of BIL Funding and additional state appropriations | Appropriation varies by state, refer to DWSRF Priority Listing information | Match requirement varies by state and community need |
A Final Word
Lead in drinking water is a growing community health concern. Water systems are required to provide more information to consumers on an annual basis beginning in October 2024. Engineers, program managers, planners, and data intelligence specialists at LaBella are actively working with municipalities to catalog lead service lines, prepare replacement plans, and implement improvements to protect community members. Partnerships between drinking water service providers, engineers, health departments, community organizations, and residents can effectively and efficiently advance the quest for safe drinking water.
This article was originally published on February 5, 2024, and was updated October 22, 2024, to reflect the US EPA Final Rule.
